''Person'' Definition In Different Laws
In Bridges v. Texas A&M University System, 790 S.W.2d 831, 834-35 (Tex. App.--Houston [14th Dist.] 1990, no writ), the court construed a definition of "person" under the Texas Insurance Code that was substantially similar to the pre- codified definition here and held that because the definition made no reference to the State or state agencies, the Legislature did not waive governmental immunity. See id.
In Lake LBJ Municipal Utility District v. Coulson & C.A.E., Inc., 839 S.W.2d 880, 890-91 (Tex. App.--Austin 1992, no writ), this Court held that article 2226, which subjected a "person" to liability for attorneys' fees, did not encompass a "governmental unit."
However, article 2226 enumerated "person" and "other legal entity" as separate and distinct categories, whereas even the pre-codified workers' compensation statute defined "person" to include "other legal entities."